Amneal strives to conduct all aspects of our business in accordance with the highest standards of business ethics and to comply with applicable laws and regulations that govern our industry.
As part of this effort, Amneal has established an enterprise-wide Corporate Ethics and Compliance Program that is designed to help the organization understand our obligations under applicable law, company policy, and industry guidance. The Ethics and Compliance Department helps guide the company through the use of training, effective and timely communication, risk identification measures, and mitigation strategy.
Oversight
The Amneal Chief Compliance Officer has primary responsibility for development and implementation of Amneal’s Corporate Ethics and Compliance Program, including drafting policies and procedures, training, monitoring, performing investigations, and responding to identified problems. The Chief Compliance Officer provides periodic reports on the operation of the Compliance Program to the Company’s Compliance Committee and the Audit Committee of the Amneal Board of Directors, the body with oversight of Amneal’s Compliance Program.
Written Standards
The Amneal Code of Business Conduct is a set of guiding principles that has been established to support Amneal’s ongoing business operations and create a framework by which all Amneal employees should measure the decisions they make. The Code of Business Conduct outlines our expectation that the company’s officers, directors, and employees will act in accordance with the law, company policies, and Amneal’s high ethical standards.
In addition to the Code of Business Conduct, Amneal has published policies and procedures that guide our employees as they perform their day-to-day activities. These policies have been designed to ensure Amneal’s compliance with applicable laws, industry codes, and requirements for participation in government healthcare programs.
Effective Communication
Amneal works to foster a culture where employees can raise concerns and ask questions. The Company has established systems and processes to facilitate employees and all stakeholders to report concerns and suspected or actual violations of Amneal’s Code of Business Conduct, policies and procedures, or applicable laws, without fear of retribution or retaliation. Amneal also maintains a hotline that allows for anonymous reporting of any compliance concerns and a process for investigating and documenting those concerns. Reports can be made to the Amneal Ethics & Compliance Hotline online at amneal.ethicspoint.com, or toll-free by telephone at 1-877-412-8817.
Amneal expects its employees, officers, and directors to promptly report suspected or actual violations of company policies, as well as the laws and regulations governing our business. Amneal encourages its employees to raise concerns to a supervisor, department head, Human Resources, directly to The Ethics and Compliance Department, or by using the Amneal Ethics & Compliance Hotline.
Education and Training
Education is a key element of Amneal’s Corporate Ethics and Compliance Program and as such we are committed to implementing a training program that is designed to provide our employees with information needed to execute their job responsibilities in an effective and compliant manner and to help employees better understand the impact of their actions on the Company and society. Upon joining Amneal, employees will receive comprehensive training on requirements that pertain to our industry and their specific job functions. Employees will continue to receive compliance training on at least an annual basis and when relevant changes are made to the policies or regulations that govern their business conduct.
Amneal reviews and updates its training programs periodically in order to increase clarity and effectiveness and to identify areas where additional training is needed.
Auditing and Monitoring
Amneal routinely conducts auditing and monitoring of business activities to assess adherence to company policies, identify potential training needs, and ascertain the need for policy development or modification.
Accountability
Amneal colleagues and other relevant personnel are expected to adhere to our Code of Business Conduct as a condition of their employment. Any person who violates our Code of Business Conduct, or any policy or procedure, is subject to appropriate disciplinary action. Any Amneal employee who fails to report a violation of company policy or procedure of which they are or should be aware, may also be subject to disciplinary action. Amneal does not tolerate retaliation against anyone who makes a good-faith report regarding a potential violation of our Code of Business Conduct, policies or procedures, or applicable laws. The applicable guidelines are well publicized and enforced.
Remediation
Results of investigations, audits, and monitoring are communicated to appropriate Corporate Ethics & Compliance personnel and relevant business leaders. When areas of improvement are identified, Corporate Ethics & Compliance partners with Amneal functional partners to implement corrective actions.
January 2022